15.1 The Entities that will be specified in a decision of the Minister shall be required to file the Pillar Two Information Return with the Federal Tax Authority in accordance with the conditions and procedures specified in such decision.

15.2 The Pillar Two Information Return shall be filed in the standard template that was published by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting on 17 July 2023 (as amended from time to time) and shall include the following information concerning the MNE Group (which shall be specified, expanded or restricted in accordance with the Pillar Two Implementation Framework including through the development of simplified reporting procedures):

(a) identification of the Constituent Entities, including their tax identification numbers (if they exist), the Jurisdiction in which they are located and their status under the Pillar Two Rules;

(b) Information on the overall corporate structure of the MNE Group including the Controlling Interests that any Group Entity has in any other Entity of the same Group;

(c) the information necessary to compute:

i. the effective tax rate for each Jurisdiction and the Top-up Tax of each Constituent Entity under provisions equivalent to those set out under Chapter 5 of the Pillar Two Model Rules;

ii. the Top-up Tax of a member of the JV Group under provisions equivalent to those set out under Chapter 6 of the Pillar Two Model Rules;

iii. the allocation of Top-up Tax under the IIR, and the UTPR Top-up Tax Amount to each Jurisdiction, under provisions equivalent to those set out under Chapter 2 of the Pillar Two Model Rules;

(d) a record of the elections made in accordance with the relevant provisions of this Decision; and

(e) other information that is agreed as part of the Pillar Two Implementation Framework and is necessary to carry out the administration of the Pillar Two Rules.

15.3 The Pillar Two Information Return shall apply the definitions and instructions contained in the standard template that was published by the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting on 17 July 2023 (as amended from time to time).

15.4 The Pillar Two Information Return and the notifications pursuant to this Article shall be filed with the Federal Tax Authority no later than 15 months after the last day of the Reporting Fiscal Year.

15.5 The Federal Tax Authority may modify the information, filing and notification requirements of the Pillar Two Information Return to align those requirements with those provided under the Pillar Two Implementation Framework (including the development of simplified reporting procedures).

15.6 The Federal Tax Authority shall issue a decision specifying the form of the Pillar Two Information Return.